TaxTMI 
TaxTMI 
2024 (12) TMI 1375
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....nt Year 2018-19 in the order impugned), whereby the Ld. CIT(A) had dismissed the appeal of the Assessee against the Assessment Order, dated 31/10/2019, under Section 144 read with section 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Appellant has raised a number of grounds, which are descriptive/argumentative in nature, challenging the validity of the re-assessment proceedings and the addition of INR 25,66,533/- made on account of alleged bogus purchases. 3. The relevant facts in brief are that the Appellant was, at the relevant time, engaged in the business of retailer in ornaments of gold and jewellery. The appellant filed return for Assessment Year 2012-13 on 29/09/2012 declaring total income at INR.3,04,6....
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....and the addition of INR.25,66,533/- made on account of alleged bogus purchases. 6. We note that the re-assessment proceedings have been initiated on the basis of information received from the Principal Director of Income Tax (Investigation) to the effect that the Appellant had taken accommodation entries in relation to bogus purchases from M/s Rajan Gems. The Assessing Officer after verification of records found that the Assessee had made purchases of INR.11,33,022/- from the said party. In our view, in the facts of the present case, the aforesaid information received from the investigation wing formed sufficient tangible material for initiation of re-assessment proceedings under Section 147 of the Act. As per the reasons recorded, the Ass....
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.... from the notice dated 9th December 2015, issued under section 263 of the Act by the learned PCIT, he exercised his revisional jurisdiction on the issues as enumerated in Para-2 of this order. Undisputedly, after considering the explanation / submissions of the assessee, the learned PCIT has dropped proceedings under section 263 of the Act in respect of issues no.1 and 5. Thus, he has revised the assessment order by considering it as erroneous and prejudicial to the interests of Revenue in respect of issues no.2, 3 and 4. Therefore, we have to examine the validity of exercise of power under section 263 vis-a-vis the aforesaid issues on Gehna Jewellers P. Ltd. which he has revised the assessment order. Before that, we must observe, the learn....